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On 6 December 2007, the decree of the Council of Ministers on transfer pricing has been adopted (Official Gazette of 6 December 2007, No. 26722). The decree, which applies to both resident and non-resident individuals and corporations, clarifies the arm's length principle, transfer pricing methods, advance pricing agreements and transfer pricing documentation. The decree shall be retroactively applied from 1 January 2007. Procedural rules on transfer pricing published On 18 November 2007, the Ministry of Finance published Announcement No. 1 on transfer pricing, effective as of 1 January 2008. For the first time, transfer pricing regulations were introduced by the...